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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Bribery and Fraud Prevention Policy

1. Purpose and Scope

This policy outlines how {{org_field_name}} prevents, detects, and responds to bribery and fraud, ensuring compliance with the Bribery Act 2010 and other relevant legislation. Our aim is to promote a culture of integrity, transparency, and accountability across all aspects of our operations.

This policy applies to all employees, contractors, volunteers, agency staff, and business partners. It covers all activities related to the provision of domiciliary care services, including procurement, financial transactions, recruitment, and service delivery. This policy ensures that everyone associated with the company understands their responsibilities in preventing and reporting any form of bribery and fraud.

We believe that a strong anti-bribery and fraud culture not only protects our company but also upholds the rights and safety of our service users, promoting a trustworthy and ethical work environment.

2. Policy Statement

{{org_field_name}} is committed to:

• Zero tolerance towards bribery, fraud, and corruption.
• Promoting ethical conduct and accountability.
• Implementing robust systems to prevent, detect, and investigate fraud and bribery.
• Encouraging staff to report concerns without fear of retaliation.
• Ensuring transparency in financial transactions and decision-making.

We believe that integrity is fundamental to delivering safe, high-quality care and maintaining the trust of service users, families, staff, and partners. To achieve this, all employees are expected to act honestly and avoid any conduct that could lead to fraudulent activity or bribery.

3. Legal and Regulatory Framework

This policy aligns with the following legislation and standards:

• Bribery Act 2010: This Act makes it an offense to offer, promise, or give a bribe, as well as to request, agree to receive, or accept a bribe.
• Fraud Act 2006: This Act defines fraud as false representation, failing to disclose information, and abuse of position for personal gain.
• Proceeds of Crime Act 2002: This legislation deals with the confiscation of assets acquired through criminal activity.
• Public Interest Disclosure Act 1998 (Whistleblowing): Protects employees who report misconduct or wrongdoing.
• Health and Social Care Act 2008 (Regulated Activities) Regulations 2014: Ensures that care providers operate in an honest, transparent manner.
• Care Quality Commission (CQC) Fundamental Standards: Requires care providers to maintain a culture of openness and accountability.

4. Definitions

To clarify the scope of this policy, the following definitions apply:

• Bribery: Offering, giving, receiving, or soliciting something of value to influence a decision or action improperly. This includes cash payments, gifts, hospitality, and other incentives.
• Fraud: Wrongful or criminal deception intended to result in financial or personal gain. This can include false claims, forgery, and misrepresentation.
• Corruption: Abuse of power for personal gain, often involving bribery.
• Facilitation Payment: Small, unofficial payments made to expedite routine services.
• Conflict of Interest: Situations where personal interests interfere with professional duties, such as favoring a relative in procurement decisions.

5. Roles and Responsibilities

Board of Directors and Senior Management:

• Set the tone for ethical conduct and accountability.
• Ensure effective implementation and enforcement of this policy.
• Allocate resources for fraud prevention and detection.
• Conduct regular reviews of anti-bribery measures and controls.

Managers and Supervisors:

• Promote awareness of the policy among staff.
• Monitor adherence to procedures and controls.
• Act promptly on reported concerns and escalate issues as necessary.
• Provide training and resources to staff on bribery and fraud prevention.

Employees and Contractors:

• Adhere to the policy and report suspicions of fraud or bribery.
• Participate in training and awareness programmes.
• Avoid situations that could lead to conflicts of interest.
• Refuse any bribes or improper incentives and report such offers immediately.

6. Prevention Measures

6.1 Risk Assessment We conduct regular risk assessments to identify vulnerabilities to bribery and fraud. This includes evaluating:

• Financial transactions and procurement processes.
• Recruitment and staff onboarding.
• Third-party partnerships and supplier agreements.
• Areas where staff handle cash, invoices, and financial data.

By identifying high-risk areas, we can implement targeted controls and monitor activities more closely.

6.2 Due Diligence Before engaging with third parties, we:

• Conduct background checks on suppliers and contractors.
• Verify the legitimacy of business partners.
• Ensure anti-bribery clauses are included in contracts.
• Review financial stability and reputation through credit checks.

6.3 Internal Controls We implement strong internal controls to reduce fraud risk:

• Segregation of duties in financial transactions to prevent manipulation.
• Approval processes for purchases and expenses.
• Regular reconciliation of accounts and audits.
• Digital tracking of transactions to detect irregularities.

6.4 Employee Screening All new employees undergo thorough pre-employment checks, including:

• Identity and right-to-work verification.
• Enhanced Disclosure and Barring Service (DBS) checks.
• Employment history and reference checks.
• Verification of professional qualifications.

6.5 Training and Awareness Staff receive anti-bribery and fraud prevention training during induction and annual refreshers. Training covers:

• Recognising signs of fraud and bribery.
• Reporting procedures and whistleblowing.
• Understanding conflicts of interest and how to avoid them.
• Real-world case studies to highlight potential risks.

7. Reporting and Whistleblowing

We encourage staff to report concerns confidentially without fear of retaliation. Reports can be made to:

• Line managers.
• The Designated Fraud Officer.
• The Whistleblowing hotline.

All reports are treated confidentially, and whistleblowers are protected under the Public Interest Disclosure Act 1998. We ensure that individuals who report concerns are not subjected to harassment, discrimination, or disadvantage.

8. Detection and Investigation

8.1 Monitoring and Audits We conduct regular audits and data analysis to detect anomalies. Monitoring includes:

• Reviewing financial transactions for irregularities.
• Cross-checking supplier payments with delivery records.
• Investigating unusual staff expenses and overtime claims.

8.2 Investigation Procedures When fraud or bribery is suspected:

1. The concern is reported to the Designated Fraud Officer.
2. An initial assessment determines whether a full investigation is warranted.
3. An investigation team gathers evidence and interviews relevant parties.
4. Findings are documented, and appropriate action is taken.

8.3 Reporting to Authorities If criminal activity is confirmed, we report the case to:

• The Police.
• Action Fraud.
• The Care Quality Commission (CQC), if related to care services.

9. Managing Conflicts of Interest

Staff must declare any personal or financial interests that could influence their work. This includes:

• Relationships with suppliers or contractors.
• Secondary employment or business interests.
• Gifts or hospitality received from external parties.

All declarations are reviewed by senior management and recorded in the Conflict of Interest Register. Failure to declare conflicts may result in disciplinary action.

10. Gifts and Hospitality

We maintain strict guidelines for accepting gifts and hospitality:

• Gifts of low value (e.g., promotional items) may be accepted with manager approval.
• Hospitality must be proportionate and not influence decision-making.
• All gifts and hospitality are recorded in the Gifts and Hospitality Register.

Staff are encouraged to err on the side of caution and report any offers of gifts, even if they are declined.

11. Consequences of Breach

Breaches of this policy result in disciplinary action, including:

• Formal warnings.
• Suspension or termination of employment.
• Reporting to regulatory bodies or law enforcement.

The company will also seek to recover any losses resulting from fraud or bribery.

12. Monitoring and Continuous Improvement

We ensure ongoing effectiveness through:

• Regular policy reviews and updates.
• Feedback from staff and stakeholders.
• Independent audits and risk assessments.
• Sharing lessons learned from investigations.

{{org_field_name}} is committed to maintaining a culture of integrity and accountability. By adhering to this policy, we protect {{org_field_name}}, staff, and service users from the risks of bribery and fraud. All staff must familiarise themselves with this policy and act accordingly to uphold the highest ethical standards in all aspects of their work.

Through continuous vigilance, strong controls, and open communication, we aim to create an environment where fraud and bribery are not tolerated, and ethical practices are the foundation of everything we do.

13. Policy Review

This policy is reviewed annually or sooner if legislation changes. Updates are communicated to all staff, and additional training is provided if needed. We also seek feedback from staff and stakeholders to improve the policy.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
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